Created by: HSQE Dept.

SAFETY & QUALITY Approved by: HoD-HSQE

MANAGEMENT MANUAL Issue Date: 22/10/2019
Issue No: 08
Revision Date: 24/03/2023
«Imo» Company Policies Revision No: 01
DONNELLY TANKER
MANAGEMENT Page: 9 of 11
Doc. Code SQMM-CPOL Doc. Control 0000001

Human Right Policy

Respect for human rights is a fundamental value and an integral part of any corporate culture.
Human rights are respected and therefore the company is committed to supporting the
protection of these through its Human Rights Policy, of which the foundation is the Universal
Declaration of Human Rights of the United Nations (UNO), based on the Geneva
Declaration on Human Rights at Sea. All business activities are guided by the articles of
UNO.

The company conducts its business in a responsible way by respecting the human rights of its
employees both ashore and onboard as well as of its clients and other contacts.

The protection of human rights rests on the following four principals, which the company abides
by:

1. Human rights are universal. They apply at sea, as they do ashore

2. All persons at sea, without any distinction, have human rights and there is no maritime
specific reasons, for denying any person its fundamental human rights
3. All human rights established under both treaty and customary International Law must be
respected.
4. No seafarer is paying any placement fee for his/her engagement onboard any company
vessel

DIVERSITY & EQUALITY

Integrity and mutual respect are important values to the Company which aims to create equal
opportunities for all employees, both ashore and onboard and regardless of personal
background, race, social class or background, gender, citizenship status, marital status, age,
physical or health condition, sexual orientation, religion, political opinion, or any other personal
characteristic or status protected by law.

The company strongly believes that a working environment which is characterized by equal
opportunities and inclusion, is vital for sustaining the satisfaction of its employees as well as its
acceptance and recognition as a responsible service provider by its clients or others. The
Company will treat all individuals equal considering the responsibilities and duties of their
position during their recruitment, compensation, benefits, training, promotion, rotation, or
termination.

NO ACCEPTANCE OF CHILD AND FORCED LABOUR

The Company does not accept any form of child labour according to the International Labour
Organization (ILO) Conventions, nor tolerates forced or involuntary labour of any kind
 Created by: HSQE Dept.
SAFETY & QUALITY Approved by: HoD-HSQE
MANAGEMENT MANUAL Issue Date: 22/10/2019
Issue No: 08
Revision Date: 24/03/2023
«Imo» Company Policies Revision No: 01
DONNELLY TANKER
MANAGEMENT Page: 10 of 11
Doc. Code SQMM-CPOL Doc. Control 0000001

corresponding to the ILO principles. The company shall adhere to all national laws and
regulations regarding child labour.

PRIVACY AND PERSONAL INFORMATION

The company respects the privacy of all persons and will use all reasonable care to maintain
the privacy and confidentiality of personal data, and complies with the laws and regulations of
the European Union for the protection of personal information and does not tolerate
unauthorized disclosure of or provides access to such data.

The company strictly follows Article 17 of the International Covenant on civil and Political Rights
which stipulates that, no one shall be subjected to arbitrary interference with his privacy, family,
home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right
to the protection of the law against such interference or attacks.

GOVERNACE

It is known that, through the conduct of their activities, associated service providers or suppliers,
can have direct adverse impacts on human rights. For this reason the company is choosing to
work / cooperate with companies that share the same commitments to human rights, safety
company ethics and compliance, and seeks to encourage others to act in a manner consistent
with the principles underlying the commitments set out in this policy, to local laws and
regulations, to the articles of UNO and the core standards of ILO.

DISSEMINATION / EDUCATION

In order to ensure that this Policy is embedded within the culture of all employees, both ashore
and onboard, the company provides appropriate education and training opportunities to all
employees. Other service providers / suppliers are also fully encouraged to fully embrace this
Policy.

IMPLEMENTATION & REVIEW

This policy statement will be systematically reviewed and continuously improved by the top
management in order to assure suitable implementation within the Company’s management
processes and procedures. The Company ensures that this policy is communicated to all
employees, both ashore and onboard, and provides appropriate training with regards to the
impacts the business can have in order to increase their ability to protect human rights and
related issues. All company employees are encouraged to contact the CEO for shore staff and
Manning agencies/Masters for seagoing staff, in order to address any concerns about the
effective implementation and corresponding enforcement of this policy.
 Created by: HSQE Dept.
SAFETY & QUALITY Approved by: HoD-HSQE
MANAGEMENT MANUAL Issue Date: 22/10/2019
Issue No: 08
Revision Date: 24/03/2023
«Imo» Company Policies Revision No: 01
DONNELLY TANKER
MANAGEMENT Page: 11 of 11
Doc. Code SQMM-CPOL Doc. Control 0000001

Where the company identifies that it may have unintentionally caused or contributed to adverse
impacts on the human rights of others, it will ensure to provide the support or cooperate with
others, in the immediate remediation of the adverse impacts through legitimate processes
intended to deliver effective remedy while not preventing access to other forms of remedy if
justified. This may include cooperating in good faith in the provision of remedy through state-led
mechanisms. Where adverse impacts are directly linked to company activities through its
business relationships, the company will support its business partners in the remediation of
those impacts through their own grievance management processes, or support collaboration to
provide for non-judicial remediation through third parties

Chief Executive Officer